On the most recent Centers for Medicare and Medicaid Services (CMS) open door forum, CMS staff advised that the new health care reform law mandates the implementation of the new minimum data set (MDS) 3.0 with a partially delayed RUGs IV payment system as of Oct. 1. This would require CMS to come up with a "hybrid" payment system immediately changing the present rules on the "look back" and concurrent therapy while delaying other RUGs IV elements until Oct. 1, 2011. If this becomes necessary, CMS is looking at an interim payment procedure starting October 1 that would use the MDS 3.0 and make payments using the RUGs IV system in its entirety.
Once the "hybrid" payment system is in place, CMS would re-process all paid claims under RUGs IV from October 1. CMS estimates a minimum of six months to get a hybrid payment system designed, tested, and in place. AAHSA is urging Congress to prevent all this confusion by passing legislation to restore Oct. 1, 2010 as the effective date for all of RUGs IV. CMS is also hosting a national conference call on June 24 at 1:30 p.m. Eastern. This will be the first of three national calls to discuss the new payment system and registration information will be distributed this week. The first call will focus on concurrent therapy, activities of daily living, and look-back periods.